Bacterial food poisoning can be readily prevented by long
overdue basic sanitarymeasures rather than by ultrahazardous
irradiation technologies.

The food and nuclear industries, with strong government support, have
capitalized on recent outbreaks of pathogenic E.coli 0157 meat
poisoning to mobilize public acceptance of large scale food irradiation.
Already, the Food and Drug Administration (FDA) is allowing the use of
high-level radiation to "treat" beef, pork, poultry, eggs, vegetables,
fruit, flour and spices, while the United States Department of Agriculture
(USDA) proposes the imminent irradiation of imported fruit and vegetables.

Caving in to powerful corporate industry interests, both House and
Senate Appropriations Committees have recently proposed to sanitize the
FDA's already weakened labeling requirements for irradiated food by
eliminating the word "irradiated" in favor of "electronic pasteurization"
(1); this term was proposed by the San Diego based Titan corporation, an
erstwhile major defense contractor using highly costly linear accelerator
"E-beam" technology, originally designed for President Reagan's "Star
Wars" program, which shoots food with a stream of electrons travelling at
the speed of light. However, the proposed electronic pasteurization label
is a euphemistic absurdity, especially since the FDA's approved meat
radiation dosage of 450,000 rads is approximately 150 million times
greater than that of a chest X-ray, besides circumventing consumers'
fundamental right to know.

Furthermore, the new labeling initiative is reckless. Irradiated meat
is a very different product from cooked meat. Whether irradiated by linear
accelerators or pelletized radioactive isotopes, the resulting ionizing
radiation produces highly reactive free radicals and peroxides from
unsaturated fats. U.S. Army analyses in 1977 revealed major differences
between volatile chemicals formed during irradiation or cooking meat (2).
Levels of the carcinogen benzene in irradiated beef were found to be some
tenfold higher than cooked beef. Additionally, high concentrations of six
poorly characterized "unique radiolytic chemical products" admittedly
"implicated as carcinogens or carcinogenic under certain conditions," were
also identified (2).

Based on these striking changes in the chemistry of irradiated meat,
FDA's 1980 Irradiated Food Committee explicitly warned that safety testing
should be based on concentrated extracts of irradiated foods, rather than
on whole foods, to maximize the concentration of radiolytic products (3).
This would enable development of sufficient sensitivity essential for
routine safety testing. In 1984, Epstein and Gofman more specifically
urged that "stable radiolytic products could be extracted from irradiated
foods by various solvents which could then be concentrated and
subsequently tested. Until such fundamental studies are undertaken, there
is little scientific basis for accepting industry's assurances of safety"
(4). In an accompanying editorial comment, FDA was quoted as admitting
that "it is nearly impossible to detect (and test radiolytic products)
with current techniques" on the basis of which the agency's claims of
safety and regulatory abdication still persist (5).

While refusing to require standard toxicological and carcinogenicity
testing of concentrated extracts of radiolytic products from irradiated
meat and other foods, FDA instead has relied on some five studies selected
from 441 published prior to the early 1980's, on which its claims of
safety still remain based. However, the chair of FDA's Irradiated Food
Task Committee which reviewed these studies insisted that none were
adequate by 1982 standards (6), and even less so by the 1990's (7).
Furthermore, detailed analysis of these studies revealed that all were
grossly flawed and non-exculpatory (8).

These results are hardly surprising since a wide range of independent
studies prior to 1986 clearly identified mutagenic and carcinogenic
radiolytic products in irradiated food, and confirmed evidence of genetic
toxicity in tests on irradiated food (9). Studies in the 1970's, by
India's National Institute of Nutrition, reported that feeding freshly
radiated wheat to monkeys, rats, mice and to a small group of malnourished
children induced gross chromosomal abnormalities in blood or bone marrow
cells, and mutational damage in the rodents (10).

Food irradiation results in major micronutrient losses, particularly
vitamins A, C, E, and the B complex (11). As admitted by the U.S.
Department of Agriculture's (USDA) Agriculture Research Service, these
losses are synergistically increased by cooking, resulting in "empty
calorie" food (12); this is a concern of major importance for malnourished
populations. Radiation has also been used to clean up food unfit for human
consumption, such as spoiled fish, by killing odorous contaminating
bacteria.

While the USDA is strongly promoting meat and poultry irradiation, it
has been moving to deregulate and privatize the industry by promoting a
self-policing Hazard Analysis and Critical Control Point (HACCP) control
program (13); in late 2000, the agency will start a rulemaking process to
privatize meat inspection. Moreover, the Department of Energy (DOE)
continues its decades long aggressive promotion of food irradiation as a
way of reducing disposal costs of spent military and civilian nuclear fuel
by providing a commercial market for cesium nuclear wastes.

Irradiation facilities using pelletized isotopes pose risks of nuclear
accidents to communities nationwide from the hundreds of facilities
envisaged for the potentially enormous radiation market; in contrast to
nuclear power stations, these facilities are small, minimally regulated,
unlikely to be secure, and require regular replenishment of cobalt (Co-60)
or cesium (Cs-137) isotopes, entailing nationwide transportation hazards.
Furthermore, linear accelerators, besides plants using radioactive
isotopes, pose grave hazards to workers and are subject to virtually no
regulation (9, 14).

The track record of the irradiation industry is, at best, unimpressive.
Robert Alvarez, former DOE Senior Policy Advisor, recently warned that the
Nuclear Regulatory Commission files are bulging with unreported documents
on radioactive spills, worker over-exposure, and off-site radiation
leakage (15). Strangely, the Environmental Protection Agency has still
failed to require an Environmental Impact Statement prior to the siting of
food irradiation facilities.

The focus of the radiation and agribusiness industries is directed to
the highly lucrative cleanup of contaminated food rather than to
preventing contamination at its source (16). However, E. coli 0157 food
poisoning can be largely prevented by long overdue improved sanitation.
Feedlot pen sanitation, including reducing overcrowding, drinking water
disinfection and fly control, would drastically reduce cattle infection
rates. Moreover, E. coli 0157 infection rates could be virtually
eliminated by feeding hay, rather than the standard unhealthy starchy
grain diet, for seven days prior to slaughter (17). Sanitation would also
prevent water contamination from feed lot run off, incriminated in the
recent outbreak of E. coli 0157 poisoning in Walkerton, Ontario (18); run
off will remain a continuing threat even if all meat was irradiated.

Pre-slaughter, post-knocking and post-evisceration sanitation at meat
packing plants is highly effective for reducing carcass contamination
rates (16). Testing pooled carcasses for E. coli 0157 and Salmonella
contamination is economical, practical, and rapid. The expense of
producing sanitary meat would be trivial compared to the high costs of
irradiation, including possible nuclear accidents, which would be passed
on to consumers. Additional high costs are likely to result from an
anticipated international ban on the imports of irradiated U.S. food, and
also from losses of tourist revenues.

We charge that support of the "electronically pasteurized" label by the
food and radiation industries, governmental agencies, and Congress, is a
camouflaged denial of citizen's fundamental right to know. Rather than
sanitizing the label in response to special interests, Congress should
focus on sanitation and not irradiation of the nation's food supply.

Note - This article is largely based on a June 6, 2000 P.R.
Newswire press release by the Cancer Prevention Coalition and Public
Citizen.

Federation of American Societies for Experimental Biology,
Evaluation of The Health Aspects of Certain Compounds Found in
Irradiated Beef. Report to the U.S. Army Medical Research and
Development Command, Bethesda, MD, August 1977.

U.S. Food and Drug Administration. Recommendations for Evaluating
the Safety of Irradiated Food. Final Report of FDA's Irradiated Food
Committee. Washington, D.C., July 1980.

van Gemert, M. Memorandum Re: Final Report of the Task Group for
the Review of Toxicology Data on Irradiated Food. April 9, 1982.

van Gemert, M. Letter to New Jersey Assemblyman John Keller, October
19, 1993.

Public Citizen's Critical Mass Energy and Environment Program and
the Cancer Prevention Coalition. A Broken Record: How the FDA Legalized
and Continues to Legalize Food Irradiation Without Testing it for
Safety. Special Report, October 2000.